The FCA has published a new webpage setting out submission requirements for KIID/NURS-KII documents and meeting the KIID/NURS-KII content requirements. The FCA reminds firms that it has changed its requirements for providing KIID/NURS-KII documents at the point of submission of an application for authorisation of a new scheme or a notification of a change to an existing scheme. From 1 May 2014, applicants can provide a single KIID/NURS-KII document in draft form, by way of a suitable illustration of what is being proposed. Before issuing authorisation or approval, the FCA will require confirmation that any amendments made during the review process will be incorporated into the final versions to be submitted with the Form FN. With the Form FN, firms will be required to submit a KIID/NURS-KII for all unit classes being issued, unless a representative KIID/NURS-KII is being produced.
In relation to NURS-KII content, the FCA notes that it has seen content from several alternative investment fund managers (AFMs) that do not comply with the directions attached to the NURS-KII modification. AFMs are reminded that the document should be entitled “Non-UCITS retail scheme Key Investor Information” and an AFM’s liability statement should not be included in the practical information.
The FCA has also published a new webpage concerning the requirement for a scheme’s depositary to provide a signature on Forms 21 and 251. The FCA states that it understands that there is concern that the requirement for the original documents to be signed by all parties introduces unnecessary problems and delays. However, it also notes that these documents may be submitted electronically.
View KIID/NURS-KII requirements, 1 May 2014
View Depositary signatures, 1 May 2014